- U.S. companies (including affiliates and subsidiaries), joint ventures, sole proprietorships, citizens or resident-aliens, whether or not they act within or outside of the United States.
- All officers, directors, shareholders, employees, or agents acting on behalf of a U.S. company or person.
- With regards to non-U.S. joint ventures or consortia, in the event MIQ is the majority partner or owner, the Joint-Venture or consortium is subject to the FCPA. In instances where MIQ is not a majority owner in a non-U.S. JV or consortium, MIQ is obligated to use its best efforts to ensure that entity complies with the FCPA, including conducting due diligence on each partner or owner of the JV, and may be held liable for actions of the JV or consortium that violate the FCPA if it is determined that MIQ did not use its best efforts to ensure compliance with the law.
- Employees or companies using interstate commerce in the U.S. (including, e.g., telephone, email, bank wires) in furtherance of a bribe – whether it is done directly or through an agent.
- Non-U.S. individuals and companies committing some act in furtherance of a bribe in the U.S.
- An “issuer” under U.S. security laws, generally meaning any company listed on the U.S. stock exchanges (including American Depository Receipts), regardless of its country of origin.